THE PESTICIDE LABEL AND LABELING

The Laws Regulating Pesticides 4 Federal Insecticide, Fungicide & Rodenticide Act (FIFRA) [as revised] 4 Louisiana Pesticide Law [Title 3, Chapter 20 LRS] 4 Rules & Regulations Written to Enforce Laws 4 State Primacy

What is a Pesticide? “means any substance or mixture of substances intended for preventing, destroying, repelling, or mitigating any pest and any substance or combination of substances intended for use as a plant regulator, defoliant, desiccant, or any substance the commissioner determines to be a pesticide.” Title 3, Chapter 20 LRS

What is a Pest? “means any insect, rodent, nematode, fungus, weed, or any other form of terrestrial or aquatic plant or animal life or virus, bacteria, or other microorganism, except viruses, bacteria, or other microorganism in living humans or other living animals, which the commissioner declares to be a pest.” Title 3, Chapter 20 LRS

Types of Pesticides pest name + cide = pesticide types Insecticide Molluscicide Rodenticide Repellent Herbicide Desiccant Fungicide Defoliant Nematicide Disinfectant Avicide etc. Piscicide

Pesticide Chemical Names 4 chemical name –n-(phosphonomethyl)glycine –(±) α-Cyano (3-phenoxyphenol)methyl (±) cis/trans 3-(2,2-dichloroethenyl)-2,2- dimethylcyclopropane carboxylate

4 common name –glyphosate –cypermethrin 4 brand name –Roundup®,Touchdown®, Accord®,Rodeo®, AquaNeat®, Razor®, Eagre®, Prosecutor® –Ammo®, Cymbush®, Cynoff®, Demon®, Prevail®

FIFRA 4 Section 12. Unlawful acts –(a)(12)(G) to use any registered pesticide in a manner inconsistent with its labeling

Confusing Terminology Label vs. Labeling vs. Labeling by Reference

Labeling Requirements 4 Legal Requirements found in: 40 CFR 156 Subpart A: General Provisions Subpart B: Worker Protection Statements The Label adheres to Federal Requirements

Labeling Requirements 4 Name, brand. or trademark –must not be false or misleading –must be approved by the Administrator through registration or supplemental registration

4 Name and address of producer, registrant, or person for whom it was produced 4 Net weight or measure of contents –standard American units of measurement

4 Product registration number –Section 3 –Section 5 –Section 18 –Section 24c –Section 25b –Producing establishment registration number

4 Ingredient statement –on the front panel of the label –active ingredients by chemical name or common name with CAS # –statement of percentages –inert (other) ingredients

4 Warning and precautionary statements –required front panel statements human hazard signal signal word child hazard warning “keep out of reach of children” statement of practical treatment (first aid)

First Aid Statements 4 If the AI is an OP or carbamate must state “contains an (organophosphate or N-methyl carbamate) that inhibits cholinesterase) 4 Note to Physicians if product is in Category 1 toxicity or corrosive

To Be Included with First Aid Statement 4 Either at beginning or end 4 “Have the product container or label with you when calling a poison control center, a doctor or going for treatment” 4 Emergency Telephone Numbers

4 other required warnings precautionary statements 4 hazards to humans and domestic animals a particular hazard –routes of exposure –precautions to be taken to avoid accidents,etc.

Precautionary statements by toxicity category 4 Toxicity I: Oral, inhalation, or dermal –Fatal (poisonous) if swallowed [inhaled or absorbed through skin]. Do not breathe vapor [dust or spray mist].Do not get in eyes, on skin, or on clothing. [Front panel statement of practical treatment required.] 4 Toxicity I: Skin and eye local effects –Corrosive, causes eye and skin damage [or skin irritation]. Do not get in eyes, on skin, or on clothing.

–Wear goggles or face shield and rubber gloves when handling. Harmful or fatal if swallowed. [Appropriate first aid statement required] 4 Toxicity II: Oral, inhalation, or dermal toxicity –May be fatal if swallowed [inhaled or absorbed through skin]. Do not... 4 Toxicity II: Skin and eye local effects –Causes eye [and skin] irritation. Do not...

4 Toxicity III: Oral, inhalation, or dermal toxicity –Harmful if swallowed [inhaled or absorbed through the skin] Avoid... 4 Toxicity III: Skin or eye local effects –Avoid contact with skin, eyes, or clothing. In case of contact immediately flush eyes and skin with plenty of water.

4 environmental hazards –toxic to wildlife –toxic to fish –keep out of lakes, ponds, or streams

4 physical or chemical hazards flammable corrosive special requirements for total release foggers –e.g., Do not use more than one fogger per room. Do not use in small, enclosed spaces such as closets, cabinets, or under counters or tables. Do not use in a room 5ft.x5ft. or smaller.... Turn off all ignition sources, such as pilot lights, other open flames, or running electrical appliances that cycle on & off (refrigerators, thermostats)..."

Directions for Use 4 may appear on any portion of the label provided that they are conspicuous enough to be easily read –may appear on printed or graphic matter which accompanies the pesticide if it is securely attached or placed within the outside wrapper or bag –the label bears a reference to the directions for use in accompanying leaflets or circulars

Directions for Use (cont) 4 contents of directions for use –use classification –misuse statement

Directions for Use (cont) 4 site(s) of application target pest(s) associated with each site 4 dosage with each site and pest 4 method of application, including instructions for dilution, if required, & type(s) of application equipment required 4 frequency & timing of application

Directions for use (continued) –specific directions concerning the storage and disposal of pesticide and container, grouped and appear under the heading “Storage and Disposal”

Directions for Use (cont) –any limitations or restrictions on use required to prevent unreasonable adverse effects, such as rotational crop restrictions warnings as required against use on certain crops, animals, objects, or in or adjacent to certain areas PHI special directions for total release fogger

Directions for Use (cont) 4 statement of use classification –general use classification “General Classification” immediately below the heading “Directions for Use” now referred to as “Unclassified” nothing is on the label

Directions for Use (cont) –restricted use classification must be on the front panel-”Restricted Use Pesticide” directly below, a summary statement of the terms of restriction imposed as a precondition to registration shall appear

Worker Protection Standard Requirements 4 WPS Statements –Incorporate by reference the WPS, 40 CFR 170 into labeling –Pertain to REIs, PPE, and Notification –General Statements: near the beginning of the DIRECTIONS FOR USE under the heading AGRICULTURAL USE REQUIREMENTS

“Do not apply this product in a way that will contact workers or other persons, either directly or through drift. Only protected handlers may be in the area during application” “use this product only in accordance with its labeling and with the Worker Protection Standard, 40 CFR Part 170”

Pesticide Registration Notices (PR) : Disposal Instructions on Non- Antimicrobial Residential/Household Use Pesticide Product Labels X: Spray and Dust Drift Label Statements for Pesticide Products : Guidance for Pesticide Registrants on Pesticide Resistance Management Labeling

PR Notices (continued) X: Pesticide Label Identification for Pesticide Products meeting the Requirements of the National Organic Program : Insect Repellants: Labeling Restrictions for Use on Infants and Children and Restrictions on Food Fragrances and Colors

PR Notices (continued) : First Aid Statements on Pesticide Product Labels XX: Bee Precautionary Labeling Statements : Guidance for Mandatory and Advisory Labeling Statements XX: Indoor Residential Insecticide Product Label Statements

4 MANDATORY STATEMENTS: generally relate to the actions necessary to ensure the proper use of the pesticide & to prevent the occurrence of unreasonable adverse effects. Includes directions for use & precautions that direct the user to take or avoid specific actions –The directions & precautions specify where, when, & how a pesticide is to be applied –Generally written in imperative or direct sentences e.g., “Do not use…,” Users must…, “Wear…, Apply immediately after mixing”, Apply to corn at a maximum rate of one to two pounds per acre 30 days prior to harvest.”

4 ADVISORY STATEMENTS: provide information to the product user on such topics as product characteristics & how to maximize safety & efficacy while using the product –Are acceptable as long as they do not conflict with mandatory statements, & are not false or misleading –Best written in descriptive or nondirective terms e. g., “latex gloves provide the best protection” “applying the product immediately after preparation assures that it is in suspension. If application is delayed, agitation to re-mix the products & checking for resuspension ensures proper blending.”

PR Notices (continued) : Flammability Labeling Requirements for Total Release Foggers : Use of Term “Inert” in the Label Statements : Use of Common Names for Active Ingredients on Pesticide Labeling : Consumer Access Numbers on Pesticide Labels

PR Notices (continued) : Termiticide Labeling : Pet Pesticide Product Label Statements : Labeling Statements prohibiting Application to Water : Material Safety Data Sheets as Pesticide Labeling :False and Misleading Statements

READ THE LABEL!

UNDERSTAND THE LABEL!

FOLLOW THE LABEL!

REMEMBER: THE LABEL IS THE LAW!

Instructions First you’ve got to read them Then you have to heed them You never know when you’re going to need them. As old Elijah said to Jezebel, “You better start to learn your lessons well” from Godspell » Steven Schwartz

“Treat the Earth Well. It Was Not Given to Us by Our Parents; It Was Loaned To US by Our (grand) Children” Kenyan Proverb

Mary L. Grodner, Ph.D. Pesticide Safety Education Program 225/